Justia U.S. 4th Circuit Court of Appeals Opinion Summaries

Plaintiff, an inmate at a Virginia correctional facility, filed suit under 42 U.S.C. 1983, alleging that defendant's deliberate indifference to plaintiff's safety, and the resulting injuries, constituted cruel and unusual punishment in violation of the Eighth Amendment. Plaintiff was attacked by his cellmate after requesting a transfer from defendant, the Prison Housing Manager. The court concluded that genuine disputes of material fact underlie plaintiff's claim where plaintiff alleged specific facts describing the injuries he sustained as a result of the attack, and alleged two independent grounds for establishing defendant's subjective knowledge of the risk of assault. Therefore, the district court erred in granting summary judgment to defendant. The court vacated and remanded. View "Raynor v. Pugh" on Justia Law

Plaintiff filed suit after her termination against her former employers for disability discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), and for other violations of state and federal law. The jury found in favor of plaintiff on certain state law claims and in favor of the employers on all other claims. The court concluded that the district court correctly applied a but-for causation standard to plaintiff's ADA claim; the court rejected plaintiff's claim that the district court erred in instructing the jury where the "prevents or significantly restricts" standard is too demanding under the ADA Amendments Act, Pub. L. No 110-325, section 5; even if the court assumes that the district court’s instruction was erroneous and that the error was plain, plaintiff has not shown that it affected her substantial rights; and the court rejected plaintiff's contention that the district court erred in instructing the jury on the “regarded as” prong of the definition of disability because she failed to show how she was prejudiced. Therefore, the court found no abuse of discretion and no serious prejudice to plaintiff that warrants vacating the verdict on her disability discrimination claims. Further, the court rejected plaintiff's challenge to the district court’s instruction on “record of” disability where she did not object to the instruction and on appeal did not explain how the omitted language applies to her case. Finally, the court rejected plaintiff's challenges to the damages the jury awarded on her state law claim. Accordingly, the court affirmed the judgment. View "Gentry v. East West Partners Club" on Justia Law

Plaintiffs filed suit against the City, alleging that the City, acting through it's Board of Zoning Appeals (BZA), violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., by denying plaintiffs' request for a variance to permit a certain property to be used as a church facility. The district court dismissed the complaint with prejudice. The court concluded that plaintiffs failed to state a claim that the BZA’s decision imposed a substantial burden on plaintiffs’ right of religious exercise. The court also concluded that the district court did not abuse its discretion in denying plaintiffs’ request to amend their complaint, because any such amendment would have been futile. Accordingly, the court affirmed the judgment. View "Andon, LLC v. The City of Newport News, VA" on Justia Law

Maryland allows any voter to vote via absentee ballot. Plaintiffs filed suit under Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12132, and Section 504 of the Rehabilitation Act, 29 U.S.C. 794, against state election officials under federal law, alleging that marking a hardcopy ballot by hand without assistance is impossible for voters with various disabilities, and that they have therefore been denied meaningful access to absentee voting. Defendants argue that even if absentee voting is not fully accessible, the full accessibility of Maryland’s in-person polling places provides disabled voters with meaningful access to voting. The court concluded that defendants’ proposed focus is overbroad and would undermine the purpose of the ADA and its implementing regulations. Therefore, the court affirmed the district court’s conclusion that by effectively requiring disabled individuals to rely on the assistance of others to vote absentee, defendants have not provided plaintiffs with meaningful access to Maryland’s absentee voting program. The court also concluded that plaintiffs’ proposed use of the online ballot marking tool is a reasonable modification to Maryland’s absentee voting policies and procedures. The court agreed with the the district court that defendants have not met their burden to show that plaintiffs’ proposed modification - use of the online ballot marking tool - would fundamentally alter Maryland’s voting program. Accordingly, the court affirmed the judgment. View "National Federation of the Blind v. Lamone" on Justia Law

Plaintiffs filed suit challenging Maryland's Firearm Safety Act (FSA), Md. Code, Crim. Law 4-303(a), which, among other things, bans law-abiding citizens, with the exception of retired law enforcement officers, from possessing the vast majority of semi-automatic rifles commonly kept by several million American citizens for defending their families and homes and other lawful purposes. The court concluded that the FSA implicates the core protection of the Second Amendment and the court, pursuant to District of Columbia v. Heller, McDonald v. City of Chicago, and its own precedent, concluded the burden is substantial and strict scrutiny is the applicable standard of review for plaintiffs’ Second Amendment claim. Therefore, the court vacated the district court's denial of these claims and remanded for the district court to apply strict scrutiny. The court affirmed the district court's denial of plaintiffs' equal protection challenge to the statutory exception allowing retired law enforcement officers to possess prohibited semi-automatic rifles. Finally, the court affirmed the district court’s conclusion that the term “copies” as used by the FSA is not unconstitutionally vague. View "Kolbe v. Hogan, Jr." on Justia Law

The Estate of Ronald H. Armstrong appealed the district court's grant of summary judgment to the Village and members of the police department on its excessive force claims. The court held that defendants used unconstitutionally excessive force when seizing Armstrong. Had defendants limited themselves to permissible uses of force when seizing Armstrong, they would have had every tool needed to control and resolve the situation at their disposal. However, the court concluded that defendants are entitled to qualified immunity where Armstrong’s right not to be tased while offering stationary and non-violent resistance to a lawful seizure was not clearly established. Accordingly, the court affirmed the judgment. View "Estate of Ronald Armstrong v. The Village of Pinehurst" on Justia Law

After plaintiff flunked out of the FBI Academy by failing to perform the required amount of push-ups, he filed suit under Title VII of the Civil Rights Act, 42 U.S.C. 2000e-16(c). Plaintiff alleged that the FBI discriminated against him on the basis of sex, in that female New Agent Trainees were required to complete only fourteen push-ups. The district court granted plaintiff's motion for summary judgment and the Attorney General appealed. The court held that an employer does not contravene Title VII when it utilizes physical fitness standards that distinguish between the sexes on the basis of their physiological differences but impose an equal burden of compliance on both men and women, requiring the same level of physical fitness of each. Because the FBI purports to assess physical fitness by imposing the same burden on both men and women, this rule applies to plaintiff’s Title VII claims. The court concluded that the district court erred in failing to apply the rule in its disposition of plaintiff's summary judgment motion. Accordingly, the court vacated the judgment and remanded for further proceedings. View "Bauer v. Lynch" on Justia Law

Plaintiff filed suit under the Federal Tort Claims Act (FTCA), 28 U.S.C. 1346(b), against the United States, alleging that prison officials were negligent in failing to protect him from an attack by several other inmates. The district court granted the government’s motion to dismiss for lack of subject matter jurisdiction. The court affirmed the district court’s holding that the prison officials’ discretionary decision not to separate plaintiff from his attackers is subject to the discretionary function exception of the FTCA, depriving the court of jurisdiction over that claim. In regard to plaintiff's claim that prison officials did not perform the searches of other inmates properly, the court remanded for additional discovery because jurisdictional facts are intertwined with the merits of that claim. Accordingly, the court affirmed in part, vacated in part, and remanded. View "Rich v. United States" on Justia Law

Plaintiff collapsed with exertional heatstroke while practicing as a member of the Towson University football team. Plaintiff was in a coma for nine days, almost died, and suffered multi-organ failure, requiring a liver a transplant and numerous additional surgeries. Plaintiff subsequently recovered and pursued his plan to return to playing football. However, the Team Physician, a board-certified sports medicine doctor, concluded that allowing plaintiff to participate in the football program at the University presented an unacceptable risk of serious reinjury or death. Plaintiff filed suit against the University, alleging that its decision to exclude him from the football program amounted to a violation of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Section 504 of the Rehabilitation Act, 29 U.S.C. 701 et seq. The district court entered judgment against the University. The court reversed, concluding that plaintiff was not “otherwise qualified” to participate fully in the University’s football program because the University reasonably applied its Return-to-Play Policy. The court was required to give deference to the University's judgment. The court did not reach the University's challenge to the district court's evidentiary rulings. View "Class v. Towson Univ." on Justia Law

Plaintiff filed suit against the police department and three of its former detectives for damages under 42 U.S.C. 1983, alleging that the police and prosecution withheld evidence in violation of Brady v. Maryland during plaintiff's 1982 murder trial. The district court dismissed the case under Heck v. Humphrey. The court affirmed the judgment, concluding that this case involves section 1983 claims that are predicated on alleged Brady violations which would, if proven, necessarily imply the invalidity of plaintiff's convictions. Those convictions have not been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal, or called into question by a federal court's issuance of a writ of habeas corpus. Therefore, under Heck, they may not be collaterally attacked through section 1983 now. The court concluded that the fact that plaintiff is no longer in custody does not change this result. Finally, plaintiff has identified no impediment to habeas access warranting an expansion of the Heck exception. View "Griffin v. Baltimore Police Dept." on Justia Law